In a Business-to-Consumer (B2C) data processing agreement, what distinct category of regulatory risk arises from a failure to explicitly address data subject rights (e.g., right to access, erasure) under data protection regulations, beyond general data security measures?

The distinct category of regulatory risk arising from a failure to explicitly address data subject rights, such as the right to access or erasure, in a Business-to-Consumer (B2C) data processing agreement, beyond general data security measures, is rights-based compliance risk or accountability risk specific to data subject requests. This risk is distinct from data security because it pertains to the organization's ability to fulfill its procedural and substantive obligations to individuals regarding their personal data, rather than solely preventing unauthorized access or loss. Data subject rights are legal entitlements granted to individuals, or 'data subjects,' allowing them control over how their 'personal data,' which is any information relating to an identified or identifiable natural person, is processed. Examples include the right to access a copy of their data, the right to request correction (rectification) of inaccurate data, the right to have their data deleted (erasure or 'right to be forgotten'), the right to restrict processing, the right to data portability (receiving data in a structured, commonly used format), and the right to object to certain processing activities. A B2C data processing agreement involves a business directly interacting with individual consumers, making the clear handling of these rights paramount. Failure to explicitly address these rights means the agreement lacks defined processes, responsibilities, and timelines for how the business, or any third-party processor it engages, will receive, verify, respond to, and fulfill data subject requests. This omission leads to several specific regulatory consequences. Firstly, it results in direct violations of data protection regulations, such as the General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), which mandate specific procedures and deadlines for responding to such requests, leading to significant regulatory fines or penalties. For example, if a consumer requests their data be deleted, and the business has no clear process or contractual obligation with its data processor to fulfill this, the regulated deadline will likely be missed, incurring non-compliance penalties. Secondly, it creates a lack of operational clarity and accountability, meaning the business cannot demonstrate to regulatory authorities that it has appropriate technical and organizational measures in place to facilitate and comply with data subject rights requests, violating the 'accountability principle' found in many privacy laws. Thirdly, this failure exposes the business to increased risk of consumer complaints, legal challenges, and potential class-action lawsuits directly from data subjects whose rights have not been honored. Lastly, it can severely damage the business's reputation and consumer trust, leading to a loss of market share, as consumers become increasingly aware of and sensitive to their data privacy rights.