My personal thoughts are that intelligence and military should be separate portfolios. Particularly in GCRs, intelligence concerns are far greater than merely provision of battle related information to the military. I've always regarded militaries as capable of conducting their own intelligence operations without the need for them to have a separate intelligence department. But if everyone else disagrees with that, and thinks the two divisions are good like this, I don't particularly mind.
I will say I find this whole hierarchy to be something of a mess. Delegate > Field Commander > The two division heads > Everyone else. I would have suggested simply: Delegate (CinC) > The divison heads, War Lord (or whatever) and Spymaster. Otherwise we have this elaborate chain of command that has as far as I can tell little purpose. I suppose the problem with this would be intel would no longer be subject to the appointed commander though, which I guess was the whole point of the bill, so I don't know. It's just my opinion that the whole thing is messy - no other military I can think of has such a convoluted command structure.
My final point would be I dislike the PM appointing the Commander. Partially because I don't like the PM office as noted elsewhere, and more importantly because I think the military head should always be appointed or at the very least confirmed by the Delegate, since they must remain CinC.
A final note; betrayal of information is just treason, I don't think it qualifies as high treason. The latter is usually reserved for absolutely colossal betrayals.