Well, with that, I would simply say I can appreciate that when it comes to subparagraph 8(2)(m)(i) where the head of the institution has more authority, but, frankly, when it comes to the rest of section 8, I don't see any difference between the Information Commissioner compelling disclosure and a department compelling disclosure where it implicates personal information.
Frankly, if you want to be consulted on all of section 8, I think you have to make a case as to why there's a difference between the Information Commissioner and the department.