Don't know your application but a hole-slot is always preferable for a functional assembly.
I get the felling that you a) are trying to put your own style on the way you call this out b) don't fully understand datum and the order of precedence c)that you are trying to apply a midplane datum to a cylindrical feature.
In any case, just put a FOS callout on each hole and apply a datum to each. As long as neither is not primary,then reference one with respect to the other you have than achieved what I believe you are looking for which is locking the remaining 3 DOF, x and y translation are locked with one hole and last is the z-rotation with the other. This should be clear to all who have a basic GD&T understanding.
An item of note is that if your pattern of two holes is located in a manner in which you can't tell them apart, since they are equal in size, then you are opening yourself to some more confusion not to mention R&R issues.
Advice, use a slot and apply the tertiary datum to the slot FOS. It doesn't have to be much of one, and be done with it, your manufacturing/assembly will thank you in the end.