certain wheels can be quite flexible when side loaded i.e. going up a big climb standing up and moving side to side, and heavier or more aggressive riders will experience this more often?
my Fulcrum Racing 5s do this, I can get the back wheel to swish against the brake blocks on a steep climb, especially noticeable in the wet
Last week I borrowed an aero bike with full carbon wheels and was blown away by the speed on the flat, but could get the rear wheel to swish against the brake blocks by just wiggling my bum hard sat down in the saddle.
My handbuilts in contrast are rock solid with 32 spoke x 3 cross lacing and I have never been able to get any brake block contact out of those wheels no matter what I have tried!