The only reason I'm asking is that I want to refer to “guidelines on treating the identity of a requester as personal information”. These are TBS's guidelines. It says: “The identity of an individual who has requested information under the Access to Information Act or the Privacy Act is considered to be personal information, and should be treated as such in the course of processing a request...”. You went through your reasoning for that—because you feel that it's under the definition of personal information under the Privacy Act.
It then goes on to say, “In some circumstances it is appropriate to disclose the identity of a requester to a departmental official...”. There is nothing else in the TBS guideline that indicates that it's appropriate to disclose it to anyone else. The guideline says, in some cases, it's appropriate to disclose it to a departmental official.
So what is TBS's definition of a departmental official?