Airports are safety critical hubs in both the physical and digital sense. Heathrow’s operational model depends on tightly coupled systems operated by airlines, handlers, third party service providers and the airport operator itself. That coupling is the source of efficiency and the same coupling is the source of systemic fragility when ransomware hits a supplier or shared platform. Exercises that treat cyber as an IT problem alone miss the point. Effective ransomware drills at Heathrow must be operational, contractual and legal exercises at the same time.

Start with the legal baseline. Under UK data protection laws organisations must assess and, where required, notify the Information Commissioner’s Office within 72 hours of becoming aware of a reportable personal data breach. Simulated incidents must therefore include the mechanics of breach assessment and timed notification workflows so that staff stop practising until‑we‑have‑everything and start practising report‑early, update‑later behaviour. At the same time the emerging Cyber Security and Resilience Bill creates new regulatory levers over critical suppliers and reporting that will tighten expectations for airports and the vendors they rely on. Drills are the moment to practise those statutory interactions with regulators and to confirm who leads what in the first hours.

Design the exercise to be multi‑layered. A good program combines a senior tabletop for decision makers, technical red team simulations for IT, and a live operational failover that takes one passenger processing pathway offline and forces manual processing for a measured window. Tabletop alone will expose governance gaps. A live manual fallback exposes operational assumptions that are invisible behind screens: the availability of paper tickets, printers, ribbon supplies, staff trained in manual tag and manifest procedures, and secure physical handling of passenger data. Heathrow should require every live drill to include airlines, ground handlers, Border Force, police, baggage services, the vendor for the affected service, and representatives from the Department for Transport or its delegated incident coordination body. Exercise templates from national agencies exist for this purpose and should be used as a baseline.

Treat suppliers as active players, not passive injects. The largest single operational risk in modern aviation is supplier concentration: a single third‑party platform can cascade to multiple airports and carriers simultaneously. Contracts should mandate not only security controls but also testability: scheduled failover tests, requirements to participate in industry‑wide exercises, escrow or build‑your‑own continuity arrangements, and auditable logs to support forensic work. Where suppliers operate common‑use platforms, the airport must have pre‑agreed protocols for isolation, command and control of shared services during a crisis. Simulate the contract triggers, the vendor escalation ladders, and the real world friction of 24/7 vendor availability in your drills.

Operational realism means injecting the regulatory and commercial pressures you will face in a real event. Include a media team that must produce timed statements, and a legal team that must advise on ransom considerations and sanctions risk. The NCSC guidance on considering ransom payments is blunt: payment is not a technical panacea, it does not discharge regulatory obligations, and it raises complex insurance and sanctions questions that need to be resolved at board level before they arise. Rehearse the decision tree: technical feasibility of recovery, insurer engagement, law enforcement notification, legal risks around payments, and public communications. Recording those decisions and the rationale in real time is as important as the technical recovery steps.

Exercise the evidence chain. Forensic integrity and investigatory cooperation with law enforcement are legal requirements and operational necessities. Drills must practise log preservation, isolated forensic images, secure chain of custody for evidence and coordinated briefings to national incident responders. That includes a tested path to escalate to national cyber authorities and, where relevant, to the regulator designated under sector resilience regimes. Simulate Freedom of Information or parliamentary enquiries in a controlled way so spokespersons learn to give timely accurate answers without legal over‑reach.

Measure what matters and publish after‑action learning. The point of exercises is to harden reality not to create public theatre. That said, credible after action reports that document decisions, timings, gaps and corrective actions build trust across stakeholders and with the regulator. Use performance metrics that matter to passengers and commerce: time to activate manual processing, time to full passenger throughput for a terminal operating in degraded mode, time to notify regulators, and time to restore and validate vendor updates. Make remediation deadlines contractual and publishable where they affect public safety.

A final practical checklist for Heathrow operators and partners:

  • Convene a cross‑functional steering group with legal, operations, IT, communications, and vendor representatives. Practice governance roles until they are muscle memory.
  • Run at least two exercises per year: one senior tabletop and one live degraded‑operations drill that forcibly switches passenger processing to manual for a realistic window.
  • Include supplier contractual testing clauses that mandate participation in vendor failure drills and provide for escrow or portable continuity for mission critical SaaS.
  • Test regulatory and breach notification workflows under a timed 72‑hour constraint and rehearse contact with the ICO and sector regulators.
  • Pre‑agree roles for law enforcement and national cyber authorities and practise evidence preservation and coordinated briefings.
  • Decide policy on ransom payments at board level, document the decision process, and rehearse communications about that choice. Use NCSC guidance as the operational baseline.

Ransomware is now a systemic safety issue for airports. Heathrow cannot afford to treat cyber resilience as a checkbox. Realistic drills that link legal obligations, supplier governance and live operational fallbacks are the single most cost effective investment an operator can make to avoid weeks of disruption and cascading legal exposure when the inevitable incident occurs. Regulators will continue to raise the floor. Airports that have practised under pressure will be the ones that keep passengers moving and that can justify their decisions to courts, regulators and the travelling public.