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incrediBILL - 5:35 pm on May 10, 2009 (gmt 0)
I'm not aware of anything like that possible in recent years, but of course I'm not in the NSA so anything is theoretically possible but the newer media should make such recovery hard. Back in the early 80s it was childs play. It's been a while since I've actually worked on the low level drive controllers but even losing sector index marks didn't mean I couldn't recover data from a HDD because I could read an entire track and just pull in all the data on the track regardless of the formatting marks and then analyze what was left. Complete and utter destruction is best but low level reformat is probably good enough.
incrediBILL, since you worked in the industry, are you aware of any instance in which useful data was recovered from a hard disk which had been wiped by overwriting with random data?