Yes, if the device is functional and they know their screen lock passcode, some data recovery may be possible. Why I said a damaged device.
Regardless, having a backup, up to date and ready to restore, makes any and all of that moot to begin with.
That is my pet crusade - to just get people to realize a backup can solve most of the posts ever made here. I bought my own first computer in 1984. Since then I have owned, ... well honestly I don’t know how many personal computing devices (its over 50, desktops, luggables, laptops, tablets, cell phones, smart phones), the majority of them Apple. I have never once lost data - not to a hurricane, power outages, water damage, loss or theft. But I always, always have backups of all my devicees data or at least that submit of it I care about.
My current MacBook Pro uses 3 redundant backups (Time Machine, and two CCC clones, one kept in a fire safe) and all my iOS devices are backed up daily to iCloud, and weekly (or more frequently) to iTunes. Photos are transferred to my Mac and backed up with it. Contacts are archived on my Mac and iCloud. Passwords, security question answers, notes, recovery codes and so forth are in my iCloud keychain and independently in mSecure (which is backed up to the Mac and its backups).
While that may sound complicated, it’s really not once set up and used routinely. And it’s a heck of a lot easier to deal with than scrabbling to recover data (usually a futile effort) from a damaged or dead device.