Who pays the $100? The parent company or the subsidiary that can go bankrupt, and transfer its assets to another subsidiary for $1?
It makes more sense to assign all the blame on whatever entity lost control of the data. They get a big fine and as long as they were following best practices (as outlined by their insurance company), then their insurance company will pay the fine and the business keeps chugging along.
If the company was negligent, the fine is likely a death sentence.