This is a reasonable conceptualization, IMO. However, the problem isn't that we can't access the information in a black hole (there are other places in the universe where information becomes inaccessible).

The problem is that black holes evaporate. If the particles released via evaporation don't contain the information about the particles that entered, information is lost when the black hole is completely gone.

The proposed solution is that the information is encoded onto the surface of the black hole and thus into the hawking radiation being released from that surface.