Unless you're taking the "there are multiple mathematically incompatible ways to define bias" view of the topic, just do what's already known best practice for high-bureaucracy human review. Which is too define an overly-pedantic standard rubric.

For example, the article here shows disparate impact: that different percentages of applications are passed through the AI filter. But it doesn’t show differential treatment of otherwise identical applications based on race.

Note that the OP uses "systemic rejection", while the paper does reference bias, it is in the precise meaning of the word.[0] And this is not targeted at the general public.

You may want to look into the 1990 GOPAC handout "Language: A Key Mechanism of Control" to understand why some groups would simply just weaponize any term that was substituted. Academic papers need to error on being precise, to be effective, not focused on handling the general public with kids gloves IMHO.

Edited to add, listen to Lee Atwater's 1981 Interview on the Southern Strategy for even more context.

[0] https://arxiv.org/pdf/2605.27371

Also, we will of course have all kinds of attempts to "game" the system to get ahead. Optimizing (even more) for the metric. Degree mills, for instance.