Activate an iphone on AT&T without a data plan?

I recently upgraded from a 3G to a 4s and decided to give the 3G to a friend of mine since she wanted a iphone but didn't want to spend the money. Anyways, she doesn't have a data plan with AT&T since she was using a basic phone. I'm wondering if I could just stick in the sim and turn off data usage before AT&T gets any usage charges or would she need to get a data plan?

As soon as the phone is turned on, AT&T will charge her for data.

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