In windows, when a file is manually deleted it is flagged, but it still recoverable from the recycle bin, this space is still reported as being in use. When a file is deleted from the recycle bin or through other processes the allocation of the space the file occupied is released, but the bits of the file are still recoverable with the right tools. If data is written to the file after the space was deallocated the portions of that space may be overwritten and recovery of that data is darned near impossible.
Just because there is binary data on a location on the disk, doesn't mean it can't be used for something else, and simply doing a quick format on a disk does not remove any data that you may have had on the disk. You would have to wipe the disk or unallocated space to do that.