Earlier quoted context omitted.
Another interesting point they mention is "recovering years long deleted texts." Consider the filesystem your phone uses for volumes it's writing data to and how it (probably just) unlinks files when deleted... [edit] and I should add a 'factory reset' will probably just write a new filesystem table over the old on disk without wiping anything on most devices
What about doing a factory reset, then use the 'encrypt device' option, then doing another factory reset. Would that provide an extra measure? Unless, of course, the data in it's final state before the final factory reset is un-encrypted.
I would say if you have data on your smartphone you don't want recoverable at rest, take module0000's advice, then also use encryption, and then also use a multi-pass wipe tool on particluar files. Of course all of this could still not work.
For example, I'm not sure what the forensic ramifications of a seemingly more complex filesystem like APFS will be in the near future when it hits iOS.
[1] https://bits-please.blogspot.com/2016/06/extracting-qualcomm...