The National Labor Relations Board (NLRB) has ruled an employer does not have a duty to provide a union with relevant information that contains confidential material if the union has refused the employer’s offer to bargain over ways to protect its legitimate confidentiality interests. Oncor Electric Delivery, LLC, 369 NLRB No. 40 (Mar. 6,

Overruling Banner Estrella Medical Center, 362 NLRB 1108 (2015), the National Labor Relations Board (NLRB) has held that investigative confi­dentiality rules are lawful Category 1 rules under The Boeing Company, 365 NLRB No. 154 (2017), where by their terms the rules apply for the duration of any investi­gation. Apogee Retail LLC d/b/a Unique Thrift