This isn't quite Gutmann, but is DOD 5220.22-M, and comes from a
reliable/knowledgeable source:
http://www.sysinternals.com/Utilities/SDelete.html

Introduction

One feature of Windows NT/2000's (Win2K) C2-compliance is that it implements
object reuse protection. This means that when an application allocates file
space or virtual memory it is unable to view data that was previously stored
in the resources Windows NT/2K allocates for it. Windows NT zero-fills
memory and zeroes the sectors on disk where a file is placed before it
presents either type of resource to an application. However, object reuse
does not dictate that the space that a file occupies before it is deleted be
zeroed. This is because Windows NT/2K is designed with the assumption that
the operating system controls access to system resources. However, when the
operating system is not active it is possible to use raw disk editors and
recovery tools to view and recover data that the operating system has
deallocated. Even when you encrypt files with Win2K's Encrypting File System
(EFS), a file's original unencrypted file data is left on the disk after a
new encrypted version of the file is created.

The only way to ensure that deleted files, as well as files that you encrypt
with EFS, are safe from recovery is to use a secure delete application.
Secure delete applications overwrite a deleted file's on-disk data using
techiques that are shown to make disk data unrecoverable, even using
recovery technology that can read patterns in magnetic media that reveal
weakly deleted files. SDelete (Secure Delete) is such an application. You
can use SDelete both to securely delete existing files, as well as to
securely erase any file data that exists in the unallocated portions of a
disk (including files that you have already deleted or encrypted). SDelete
implements the Department of Defense clearing and sanitizing standard DOD
5220.22-M, to give you confidence that once deleted with SDelete, your file
data is gone forever. SDelete is presented with full source code so that you
can verify yourself that it works as advertized. Note that SDelete securely
deletes file data, but not file names located in free disk space.
[...]

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