On some filesystems the data is still there but the filenames associated with it are gone or mangled. That makes it harder to recover things. In addition, while it’s true that the contents are only overwritten when you write data to the disk, data is constantly being written to the disk. Caches are being updated, backup files are being saved, updates are being downloaded, etc. If you only delete one file the odds are decent that that part of the disk might not be used next. But, if you nuke the entire drive, then you’re probably going to lose something.






It’s not necessarily a “bulk storage” drive, it’s just not the main system drive. It would probably have less activity than the “C” drive, but other than the OS, plenty of other things might be installed on that drive. If it happens to be where someone installed their web browser, there could be plenty of churn there.