If they procrastinate, or do it sloppily, because they decide to do other things with their time than prioritize keeping their books properly, they are deliberately not doing their bookeeping.
It's the same thing with accessibility. People will say, "Our app isn't accessible, but that wasn't our deliberate choice, we just haven't tried to make our app accessible."
Nope. When you chose to spend time growth hacking instead of accessibility hacking, you deliberately chose money over accessibility.
Google does not get a pass because they didn't deliberately set out to do the wrong thing. By not choosing to do the right thing, the right way, they deliberately chose to do the wrong thing.
Are you saying they're doing it by accident? Even if so, that means they're negligently handling the data. And if not, they're purposefully disobeying the law.
Please elaborate. What is difficult? And why is it difficult?