There are utilities available that are similar to what the DOD requires to wipe drives containing classified information. I suppose if someone wants something bad enough, there is probably a way to reverse it but I haven't found it. Can't say I've gone looking for it, though. It is possible (even if it's a very remote possibility) of recovering information from a disk that has been wiped clean depending on how it was done.
The data doesn't actually go away during a regular formatting and as long as it hasn't been overwritten by another file, there are plenty of off-the-shelf programs that can retrieve everything on the disk. I've done it plenty of times at work with varying success.
Hard drives are cheap and can be physically destroyed as well.