Is ActiveSync data recoverable once account is removed on encrypted device

If an encrypted device (iPhone / iPad /  Galaxy S) is using ActiveSync to sync and the profile / account is removed / deleted on the device, is there anyway someone can still retrieve the data (email, contacts, calendar)?
drunkennoodleAsked:
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btanExec ConsultantCommented:
See my other EE sharing - if you refer explicitly to ActiveSync remote wipe and most likely still possible to be recoverable as it is not 100% when forensic means are used to attempt recovery. But as long as the device is passcode protected (in your case) and encryption key is wiped like the remote wipe, the chances are really low as the whole device information becomes inaccessible and gibberish.
http://www.experts-exchange.com/Hardware/Apple_Hardware/iPhone/Q_27019017.html#a35711072
http://www.experts-exchange.com/Security/Digital_Forensics/Q_27033668.html#a35752783

But we also want to note certain backend information in Exchange that may be recoverable if there is litigation hold enabled such as this then it is still recoverable
Litigation Hold is the process where an administrator can enable a mailbox so that any message modified or deleted by the user will be preserved if the litigation is enabled. This feature is critical when an organization wishes to keep electronic data of a specific user. This feature is only possible due the Recoverable Item Folder architecture changes introduced in Exchange Server 2010 which tracks the information, and the new design enables 4 folders that will be used by the feature: Deletions, Versions, Purges and Audit.
http://www.msexchange.org/articles-tutorials/exchange-server-2010/management-administration/using-exchange-control-panel-ecp-manage-exchange-organization-part4.html

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Alan HardistyCo-OwnerCommented:
If you are referring to the user trying to find the data that has been deleted from their mobile once the account has been removed, then it is potentially possible if they JailBreak an iPad / iPhone (no idea about Android devices) but I would think it would be rather difficult and they would have to be extremely IT literate.

Alan
btanExec ConsultantCommented:
unless the "outsider" gain access physical access and able to login to the device, all are possible to be recoverable in the use case mentioned in my post. But it is non-trivial and as shared by Alan, if device itself is "compromised" then chances of gaining access illegitimately is higher hence the recoverability exposure is greater.  In short likely recoverable
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