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Absolutely. Premised on negligence. An encrypted harddrive meets HIPAA requirements, surely doing a factory reset does a better job of destroying data than an encrypted drive. I think your paranoia is getting the better of you. Either way, simply removing the drive is a great way to prevent others from having your information.
A standard reformat simply deletes the NTFS MFT. The data is still there, you just got rid of the table of contents.
Being encrypted is a hiding the data to begin with. There was no mention if it was encrypted or not.