https://learn.microsoft.com/en-us/windows-server/administration/windows-commands/clean
"all - Specifies that each and every sector on the disk is set to
zero, which completely deletes all data contained on the disk."
One could quibble about the term 'deletion' as what actually happens is that data is overwritten. Despite popular (?) belief, overwritten data can not be recovered.
I guess that person was confusing 'clean' without parameters.
I should add that on SSD's, SD Cards, USB flash drives and also SMR hard drives not all memory can be overwritten (or zeroed) as some portion is outside LBA user space. Such space can not be addressed as access to it is blocked by the firmware.
Depending on if an SSD is intended for end user use or professional use, some 7 - 20+ % may be reserved for overprovisioning which leaves this space with potentially recoverable data. Also, this for example is low level information obtained from a 8 TB Seagate SMR drive:
User Partition
LBAs 000000000000-0000756080F9
PBAs 000000000000-000076893477
System Partition
LBAs 000000000000-00000013497F
PBAs 000000000000-000000146F3F
Media Cache Partition
LBAs 000074702556-0000756080F9
PBAs 0000759486D0-000076893477
Spare pool
PBAs: 00007578F548-00007586BDF5 RST Available: 8000 SCT Available: EF
Spare pool (Multi-IOEDC Region)
PBAs: 00007687B32C-0000768872C1 RST Available: 400 SCT Available: 1A
The media cache partition is outside LBA user space and is approximately 60 GB in size. Zero filling this drive potentially leaves 60 GB recoverable data (using Acelab PC3000 for example).