To some extent, it varies by school and even within school by dissertation committee. We can't really use archival data for dissertations here, unless the student has demonstrated through another project their ability to independently collect data. It would be totally OK for a master's thesis-- I don't know if it's worthwhile to make students collect their own data for every hurdle in grad school, as that would both impede progress and encourage simple, quick studies, like questionnaires in mass testing.
I don't understand why you'd have to go through the IRB for a project using archival data, though-- are there sensitive data involved (e.g., hipaa type stuff) and if so, are they identifiable? If not, I don't see how there could be a risk to participants, so why would you need to go through the hassle of the IRB?
PS-- there is no question that archival data can be used to produce important, impactful results. If we did a new study for every research question we ever had, we would be exceedingly wasteful of resources, to the point of being unethical. The issue is more whether doing a study using archival data provides the same learning experience as moving through the entire research process-- not just to get the experience of data collection, but to design a methodology to meet your research goals. I don't know if the data collection experience is necessary. But I do envy
73BARMYPgsp. I wish my dissertation were going to be done in April!