Not really. Since a long time ago, hard drives have spare sectors to reallocate the bad ones when a read error is encountered. If the disk has reallocated sectors, faulty sectors could keep data because they are not accessible or writable through the IDE/SATA interface anymore. After sequentially erasing the drive with dd, those sectors could be read using vendor specific commands, by manipulating the reallocation table or using a modified firmware on the drive, etc.
This does not mean that an HDD cannot be erased without damaging it, just that dd alone is not enough. Chances are small, but disks with reallocated sectors (specially 4K sectors) can still contain sensitive data.