The problem there is that you may not be able to overwrite all sectors via the ATA/SATA interface, due to remapping of bad sectors.
To deal with that, your choices are either "secure erase", which is usually a single-pass overwrite (of everything, including bad sectors), or physical destruction (degauss, shred, incinerate).
Unless you're important enough to have a super-secret black-ops team sent after you, secure erase is good enough. Someone /might/ be able to recover /some/ data by sampling the raw analogue signal from the heads and throwing a lot of computing power at it, but that's going to take a lot of effort for little reward.
Think about it: if you could recover both the most recently written data and some non-trivial fraction of whatever was on there before that, the manufacturers would find a way to sell the additional capacity.