Asking because I don't know: does that also hold true for SSDs if the sectors are overwritten (either with new data, or due to wear levelling)?
an easy alternative is just to encrypt the drive using software-based encryption and just delete the key. Windows 10 has now stopped relying on hardware-based ssd encryption because it was found some of it was just garbage.
Edit: Additional caveats: some drives can move data in and out of the non-system viewable area and dead cells cannot be written if they're no longer viable so data can still remain there.