Suppose we wanted to estimate how many car owners there are in the UK and how many of those own a Ford Fiesta, but we only have data on those people who visited Ford car showrooms in the last year. If 10% of the showroom visitors owned a Fiesta, then, because of the bias in the sample, this would certainly overestimate the proportion of Ford Fiesta owners in the country.
Estimating death rates for people with COVID-19 is currently undertaken largely along the same lines. In the UK, for example, almost all testing of COVID-19 is performed on people already hospitalised with COVID-19 symptoms. At the time of writing, there are 29,474 confirmed COVID-19 cases (analogous to car owners visiting a showroom) of whom 2,352 have died (Ford Fiesta owners who visited a showroom). But it misses out all the people with mild or no symptoms.