Only time when you can recover anything from a disc would be in situations like these:
1. The wipe software is defective and reads the harddrive parameters wrong, leaving the beginning or the end of a drive unwiped. That is why software like that need to be tested.
2. The system BIOS hands out the wrong parameters to the program (rare situation that i only have read about).
3. Someone wiped only one partition instead of the whole harddrive.
4. Because of time constraints, someone used a "smart" wipe which only overwrote existing files (allocated clusters).
5. Someone placed something in HPA/DCO which was not detected and wiped.
6. The data was not on the disc at all, it was on a USB stick or something else.
The general rule is that once wiped using a single pass - the data is gone.
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