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Apple’s Photo Bug Exposes the Myth of ‘Deleted’
(www.wired.com)
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this post was submitted on 21 May 2024
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Yes, it should, but is mostly not done. But better approach is to use an encrypted filesystem like iOS and macOS(only with fileVault enabled) does. You can not recover encrypted data.
What happened here did not happen to phones that got wiped but only to phones where one logged logged off iCloud and logged into new iCloud account. Still the same encryption keys for filesystem.
There is no proof that it ever happened to a phone that was wiped completely.
Performing secure wipes reduces the lifetime of the storage device, if you sell a PC with removable storage device, it is better to just replace it with a new one for selling, and of course use fileVault on mac, bitlocker on windows and LUKS on linux (of course on linux there are more ways and LUKS is a partition and not a filesystem)