ISO 37301 Foundation Training — Lesson 3: Operating Operational Controls, Third Parties, Due Diligence, Speak-Up, and Investigations

Learning Objectives

• Interpret the purpose, responsibilities, inputs, and decision points shaping operating operational controls, third parties, due diligence, speak-up, and investigations.
• Apply the workflow and produce compliance operational evidence pack that another practitioner can review.
• Analyze “a concern is investigated by someone with a conflict” and recommend a proportionate, evidence-based response.

Detailed Topics

• operational controls
• third-party compliance
• due diligence
• speak-up channels
• investigation process
• disciplinary actions
• documented information
• change control
• Governance, competence, communication, documentation, validation, risk, and follow-up considerations

Instructor Demonstration

The instructor demonstrates the operating operational controls, third parties, due diligence, speak-up, and investigations workflow, identifies applicable responsibilities, records checkpoints in compliance operational evidence pack, and contrasts the accepted state with a condition where a concern is investigated by someone with a conflict.

Hands-On Exercise

Complete a controlled implementation, management, audit, assessment, foundation, introduction, awareness, or transition exercise for Operating Operational Controls, Third Parties, Due Diligence, Speak-Up, and Investigations. Establish scope and criteria, collect or create evidence, examine “a concern is investigated by someone with a conflict,” reach a supported conclusion, and preserve the result in compliance operational evidence pack.

1. Confirm objectives, scope, roles, criteria, stakeholders, and expected outputs.
2. Perform the planned activities while recording assumptions, evidence, and decisions.
3. Test a normal case, an exception, and a follow-up or improvement condition.
4. Document conclusions, owners, due dates, escalation, and verification requirements.

Scenario Analysis

• Identify the requirement or principle with the strongest influence on operating operational controls, third parties, due diligence, speak-up, and investigations.
• Compare two defensible responses and explain their governance, risk, and evidence trade-offs.
• Determine how the compliance operational evidence pack should be approved, retained, reviewed, and updated.

Troubleshooting Guidance

Separate missing evidence from ineffective practice, and distinguish a documentation issue from a control, process, governance, or competence failure. Use compliance operational evidence pack to trace the earliest divergence. Treat “a concern is investigated by someone with a conflict” as a hypothesis until the response is validated against the applicable requirement and intended outcome.

Validation Checklist

• The scope, criteria, stakeholders, and intended outcome for operating operational controls, third parties, due diligence, speak-up, and investigations are explicit.
• The compliance operational evidence pack links statements and decisions to objective, reviewable support.
• Responsibilities, competence, communication, risk, legal duties, and change impact were considered where relevant.
• Findings, corrective actions, monitoring, review triggers, and improvement ownership are clear.

Lesson Outcome

Learners can apply Operating Operational Controls, Third Parties, Due Diligence, Speak-Up, and Investigations, explain the reasoning used, and defend the result through compliance operational evidence pack.