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In fact this is so well known that many of the charities that accept donated cell phones provide tools for secure deletion of data prior to shipping the phone.
It would be interesting to test the hard reset (factory reset) feature of some current phones and see what data, if any, is recoverable.
>Dear Davide Del Vecchio,
> It's also possible to recover deleted photos from almost any flash card
> in almost any device (camera, mobile, etc) - it's a way general purpose
> file systems work. Requirement to delete information securely is
> enforced in devices certified to e.g. process US military secretes. In
> this case, device must follow DoD 5220-22-M recommendations and you can
> expect secure erase. In general purpose operation systems and devices,
> to delete information securely (wipe it) some additional
> actions/utilities are usually required.
>--Tuesday, May 15, 2007, 9:09:19 PM, you wrote to
>DDV> Hello list,
>DDV> During some research, I found an intersting "feature"
>DDV> on my Nokia mobile phone; I was able to retrieve any
>DDV> apparently deleted sms/mms.