As with regular deletion, data on a disk is not fully destroyed during a high-level format. Instead, the area on the disk containing the data is merely marked as available (in whatever file system structure the format uses), and retains the old data until it is overwritten. If the formatting is done with a different file system than previously existed in the partition, some data may be overwritten that wouldn't be if the same file system had been used. However, under some file systems (e.g., NTFS, but not FAT), the file indexes (such as $MFTs under NTFS, "inodes" under ext2/3, etc.) may not be written to the same exact locations. And if the partition size is increased, even FAT file systems will overwrite more data at the beginning of that new partition.
From the perspective of preventing the recovery of sensitive data through recovery tools, the data must either be completely overwritten (every sector) with random data before the format, or the format program itself must perform this overwriting, as the
DOS FORMAT command did with floppy diskettes, filling every data sector with the byte value F6 in hex.