Privacy leads are stretched. Regulation is complex. Mistakes are easy. And too often, organisations find out too late that they weren’t as prepared or compliant as they assumed.

That’s why it’s time to borrow a proven training technique from cybersecurity: the privacy red team approach.

What is a privacy red team approach?

It’s a way to simulate internal privacy risks in a safe, controlled and constructive way. Think of it as hands-on training for your privacy function and wider teams. It’s not about adding more to the workload; it’s about making the existing work smarter.

A red team approach doesn’t require a new team or extra headcount. It’s a practical exercise you can run periodically to test whether your people, processes and culture are working as they should.

Traditional audits tend to focus on documentation and past actions. Red team exercises, on the other hand, examine behaviour in the present. They show how things actually play out in everyday situations. The goal isn’t to catch people out, but to help them learn and give privacy leads insight they can use.

Why now?

Many privacy programmes are still reactive. Teams are overwhelmed by DSARs, frustrated with poor training uptake and juggling fragmented tools. Cultural fatigue sets in. Good habits slip.

Simulating real scenarios gives teams a chance to practise before the stakes are high. You can spot gaps early, resolve issues with confidence and move from firefighting to forward planning.

This isn’t an extra task. It’s a smart way for privacy leads to train and strengthen their teams without interrupting day-to-day work.

What does this look like in practice?

A red team approach is flexible. Start small, build trust and make it part of your ongoing training rhythm. Example scenarios include:

• Mock DSAR drills: Send in test requests and track how they’re handled. Are teams prepared? Do they escalate properly? Where does it get stuck?
• Surprise DPIA requests: Ask a product team to complete one mid-project. Do they know where to start? Who owns the process? Is risk flagged correctly?
• Real-world policy tests: Ask staff to do something the “quick way.” Do they push back, ask questions or follow the right route?
• Mock Data Breaches: Simulate a breach scenario in a dedicated training session with a fictional incident based on real scenarios that are relevant to the audience. Watch how they respond, who gets involved, how quickly it is escalated, and whether the right steps are taken.

These exercises are not performance reviews. They are learning opportunities. Everyone benefits. Privacy leads see what’s working, and staff build confidence in what good looks like.

Why culture is the critical layer

Privacy lives or dies with behaviour. Most failures begin with habits, not systems. That’s why this approach needs to focus on culture rather than just control.

Ask yourself:

• Do staff see privacy as part of their job?
• Is privacy treated as a daily habit or just a compliance checkbox?
• Are people confident in what’s expected, or simply hoping to avoid mistakes?

Red team exercises highlight these cultural signals. They help privacy leads see whether their message is landing and where it needs reinforcing.

How to start

You don’t need a budget or formal sign-off. Curiosity and a learning mindset are enough to begin.

Pick one scenario. Frame it as training. Let teams know it’s about building capability, not scoring points. Debrief openly and use what you learn to make processes clearer, faster and safer next time.

Over time, it becomes part of your routine. A simple, low-fear way to build resilience into your privacy culture.