You can create a system with authorization, ACL and an audit trail with justifications. It is less complicated to implement and can be audited after the fact.

You can create a system with authorization, ACL and an audit trail with justifications. It is less complicated to implement and can be audited after the fact. When you need access to an information, the system ask a reason (a procedure number or something) the system can grant it or not and all is logged. You can have a third party or authority notified and they could grant access to more sensible information.