It can be easier to extract the data from that backup than from the phone.
Many phones automatically back up to the user's computer or to the cloud. That's going to prove extremely difficult (if not impossible) to bypass. As well as deindexing the data, they also encrypt it-and there's no known decryption key. Some iOS devices, like newer iPhones, take an additional step. If you only deleted it a few days ago, the chances are higher that it's still there somewhere. If you deleted something months ago, and you use your phone a lot, there's a good chance that the file system will have overwritten it already. The more recently you've deleted something, the less likely it will have been overwritten.
Identifying and decoding it isn't always easy, but the forensic community has extremely powerful tools that help them with this process. If the phone hasn't overwritten the deleted data, another piece of software could find it.
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