Civil penalties and advice services

Hello everyone, I have been contacted by AdviceUK member agencies who are concerned about the impact of civil penalties on their clients and their work.  Given the focus on online claims, many are considering (in addition to existing services) the provision of internet access to clients, perhaps simply through the provision of an internet cafe or similar, or internet cafe combined with some form of assisted information (eg volunteer being on hand in internet cafe to help clients with getting on to a website, entering information etc).

A number are concerned that the advice organisation or its workers could be held liable (at least by the client) if they had helped with the claim in any way.  This problem is not new, but the prospect of a civil penalty is an additional worry.  I have had a read through of this DWP memo: http://www.dwp.gov.uk/docs/m-33-12.pdf but can’t see any direct mention of advisers.  My gut feeling is that existing advice services would not need to do anything more than they should already be doing in order to demonstrate reasonableness, and that, while there is of course a real risk of clients taking agencies to task, it is a risk that can be managed (need to be very clear about client expectations and boundaries, especially in internet cafe situation, who has responsibility for further action, changes in circumstances, etc).  However, I can see why people are worried.  Does anyone have any thoughts on these issues and how they can be addressed?  .(JavaScript must be enabled to view this email address) if you want to contact me directly.  Thanks