Booking Form

CDD in a GDPR world – is your CDD Defensible, Legal and Proportionate?

Date: June 3, 2018
Start Time: 9:00 am
End Time: 5:00 pm
CPD Time:
Cost: £485.00


We are sorry but registration for this event is now closed.

Please contact us if you would like to know if spaces are still available.


As every regulated business knows AML-CTF client due diligence [CDD] verification is a critical core aspect of any regulated business’ activities.  However, along with many legal issues that CDD investigators need to consider from May 2018 staying compliant with GDPR will also be vital.  

Control of all relevant documents is a good starting point for CDD. But what materials do you need to include, retain in the process? And what about the records recording the reasons why you have kept?    

On the 13th June 2018, Comsure is hosting a specialist CDD training event, with two expert speakers:-

  • Jon Blake has over 28 years’ experience as an investigator and covert intelligence operative with the Metropolitan Police Service, New Scotland Yard.
  • Carol Brooks is a Business Psychologist, entrepreneur and coach having worked in the consultancy and training industry for 15 years

This one day workshop will combine technical knowledge and skills with the human factors that will contribute to you being confident in how you undertake Defensible, Legal and Proportionate CDD for your business.

What does Defensible, Legal and Proportionate CDD mean?

  1. Defensible CDD
    1. If challenged, could the decision be defended as legitimate
    2. Is there a record of the decision, including when, who, where and when?
    3. Is the rationale for the decision recorded?
    4. Can records stand scrutiny in a trial or tribunal?
  2. Legal CDD
    1. In compliance with the statute, both domestic and international
    2. Adhering to court rulings and stated cases
    3. Following established legal principles
    4. Compliance with contractual agreements with the client or subject of the CDD
  3. Proportionate CDD
    1. Is the method of CDD appropriate to the risk and relationship?
    2. Is the information required already in our possession (databases, records) or do we have to look for it?
    3. Are we using the least invasive method to obtain the information we need that is reasonable in all of the circumstances?
    4. What to do with the information once you have it – process, retain, share and destroy?

Workshop outcomes

  1. To understand what CDD processes need to be in place and to ensure decisions are defensible, legal and proportionate, the workshop will aim:
    1. To raise awareness of the “investigative mindset” as it can apply to CDD activities, primarily related to risk and psychological biases
    2. To consider the ideal skills and knowledge required to carry out CDD and identify any specific gaps in your business
    3. To understand and what being proportionate means when carrying out CDD.
    4. To identify how methods and procedures may need to change

What to expect from the workshop

  1. Delegates will be
    1. able to apply their knowledge, learning and thinking about their current roles.
    2. given a “CDD – Defensible, Legal and Proportionate” workbook to use in session and take away for continuous reference
    3. be allowed to bring laptops to the workshop to enable participation during these sessions
    4. Able to ask Jon and or Carol question and seek advice after the workshop.
    5. offered first refusal and discounts at future continuation workshops – Comsure plans on hosting ongoing training through 2018/19
Jon Blake


Jon Blake has over 28 years’ experience as an investigator and covert intelligence operative with the Metropolitan Police Service, New Scotland Yard, London.


Jon specialises in Internet and Cybercrime Investigation and Covert Policing.  He retired from the service in 2014 with an exemplary service record.


He has a unique blend of experience, having served in varied operational, policy development and training roles and he has been the driving force behind several ground-breaking national training and Continuing Professional Development programmes, many of which have been adopted internationally.


His last posting from 2011 to 2014 was at the UK College of Policing as the National Coordinator for Intelligence Skills, with responsibility for Open Source and Internet Investigation and related Intelligence Management/Operative skills development.

Jon sat on a number of Association of Chief Police Officers (ACPO) working groups as a Subject Matter Expert in the areas of Internet related crime and covert operations and acted as an advisor to those setting national investigative policy and procedures.


A highly sought after speaker and lecturer and passionate about his area of work, Jon has developed several training courses and specialist workshops to enhance working knowledge for those involved in on-line investigations and intelligence gathering, including those operating covertly and on the dark and deep webs.


He has delivered training and consultation services worldwide, including on behalf of the United Nations in the Middle East and Africa and supporting UK interests in the Caribbean.


He is currently working on a number of projects to ensure a cohesive approach between industry and law enforcement agencies in the fight against organised cyber-enabled and cyber-dependent criminality.


Jon is an associate lecturer in Cybercrime and Criminal Justice at the Universities of Northampton and Derby in both under and post graduate studies. He is currently reading for a Master’s degree in Information Security and Digital Forensics, developing a dissertation around the forensic detection and subsequent disruption of hacking attacks.


Carol Brooks


Carol Brooks is a Business Psychologist, entrepreneur and coach having worked in the consultancy and training industry for 15 years.


She is MD of Platinum 3P, a consultancy and training company focusing on areas of counter terrorism and crime and Gold Business Consulting which has a generic focus on leadership, change management and workforce planning.

She has a been a Non-Executive Director on the board of a large multi-site healthcare organisation, where she was Chair of the Human Resources Committee and a member of the Audit Committee.


She also chaired recruitment panels for senior appointments. She has experience working as an academic at the University of Manchester Business School, where, as a Senior Fellow, she directed, designed and delivered Executive Development programmes.


She is a Principal Practitioner of the Association of Business Psychologists, and a member of the British Psychological Society. Carol is pragmatic in her relationships with clients, always taking a problem solving and positive approach to challenges. She is known for her energy, commitment and ability to deliver for clients, even in the most ambiguous and complex of situations.






Event timetable

Session Times Session Title Content Summary
0900-0945 Introductions Roles and experience; Knowledge Check and Adopting the “Investigative Mind-Set.”
0945-1045 Planning for CDD and Sources Devising a defensible written collection plan including methodology and data sources to be considered and decision logs

Reality Check – Skills and Knowledge for your Business

1045-1115 Break  
1115-1230 Legality of CDD What laws and cases are relevant here plus local organisational policies and procedures that may be relevant and affect decision making

Reality Check – Skills and Knowledge for your Business

1230 – 1315 Lunch  
1315 - 1340 The Risk of Psychological Bias in CDD Illustrating some common biases which can manifest when we gather information and make decisions
1340 -1400 Proportionality How to communicate proportionality. European court view of this area. Threats, Risk and Mitigation.
1400-1430 Data Sources and Tools* Introduction to free and some paid online data sources, tools and methodologies to obtain, verify and corroborate information.
1430-1450 Break  
1450 1615 Data Sources and Tools Continued* Social Media, Digital Images and Web Data. Defensibility Legality, and Proportionality all anchored here.
1615-1700 Review of Learning, Plenary Sessions and Course Closure  


  • Delegates who bring laptops will be able to participate online during these sessions