FOI requests are often made because people don't trust that the "all your information is displayed here on the website" is actually all of the information that is being held on them.
What if the FOI request was supplemented with the users password (changed by them to a temporary one)?
Other possibilities would be encrypting a second copy of the patients data (each time it is stored by the user) using a public key with the corresponding private key held in escrow somewhere on a machine with no network connection. It would then be someone's job, upon receiving an FOI request, to take the patients master-encrypted record(s), put them on the non-connected computer that contains the private key, decrypt, and print out in order to reply to the FOI and then clean up.
If this ability to decrypt data exists, you have yet another layer for the FOI request.
You must track each and every time a patient's data was decrypted and by whom, and that information must be available as well.
Information that you'll probably also need to encrypt, but still be able to search by patient, date, and decrypter. (requests come through to find all records a particular employee has seen within a certain date range as well)
I can see the start of a rabbit hole, which is why organisations dealing in PID have IG teams or consultants who know the laws and know how much needs to be done.
If a patient thinks an organisation is holding out on them, that patient has a way to complain, and the complaints aren't taken lightly from what I've seen.
What if the FOI request was supplemented with the users password (changed by them to a temporary one)?
Other possibilities would be encrypting a second copy of the patients data (each time it is stored by the user) using a public key with the corresponding private key held in escrow somewhere on a machine with no network connection. It would then be someone's job, upon receiving an FOI request, to take the patients master-encrypted record(s), put them on the non-connected computer that contains the private key, decrypt, and print out in order to reply to the FOI and then clean up.