Meraki is Cloud Managed network. This implies that all configuration in general lies in the Cloud.
If the device has been factory reset, all configuration on the device is removed, and the device will attempt to contact the Cloud, inorder to download a configuration for the device. Now, if the device is also unclaimed, there will be no configuration for the device in the Cloud.
In my opinion, factory reset, and unclaim should be sufficient. The device won't be able to build a VPN tunnel into the Customers network.
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