Is Apple recycling program in Canada overseen by EPRA?

Solution 1:

Apple is pretty clear that they accept no responsibility on data privacy at the main page.

You are solely responsible for removing all data, including confidential and personal data, from the device prior to shipping. Neither Apple nor the approved partner accepts any responsibility or liability for any lost files or data.

• https://www.apple.com/recycling/nationalservices/
• https://www.apple.com/ca/trade-in/

Now, I believe Apple incentivizes all employees and partners to take care and attempt a restore / erase but as you mentioned, your product isn’t amenable to that standard process. Unless you have a specific receipt or different paperwork with respect to handling your device during refurbishment and recycling, it looks like Apple promises very little but likely goes far above what their contract states.