So the prosecution would be based on the notion that access was “unauthorized” because certain “protocols” weren’t followed even though the legally relevant principals had provided apparent authorization?

In that case, I’d support applying similarly creative and capacious legal interpretations in hunting for ways to prosecute civil servants that participated in “Resistance” activities. Prosecuting government employees for breach of disclosure obligations is always like shooting fish in a barrel. There were also widespread reports of career employees misrepresenting facts or withholding information from political appointees. I bet you could premise 18 USC 1001 prosecutions based on that.