Organizational Development, Culture and Change

Introduction and Context

Organizations operate as open systems. They obtain resources from an environment, transform those resources through people, technology and processes, and produce goods, services or social outcomes. Because markets, technologies, regulations and employee expectations change continuously, organizational effectiveness depends not only on hiring capable employees but also on the organization’s ability to learn, adapt and renew itself.

Organizational development (OD) is a planned, systematic and participative effort to improve an organization’s effectiveness, health and capacity for continuous learning. It draws on behavioral science, systems thinking, organizational psychology, management and human resource development. OD is broader than a training event and more sustainable than a short-term motivational campaign. It addresses relationships, structures, leadership, culture, work processes and the alignment between organizational purpose and employee experience.

This chapter explains how HR professionals can diagnose organizational problems, select appropriate change approaches, design team and culture interventions, strengthen employee engagement, and manage resistance ethically. The central argument is that successful change requires alignment: between strategy and structure, values and behavior, leadership messages and managerial practice, and intended change and lived employee experience.

Learning Objectives

By the end of this chapter, students should be able to:

1. Explain organizational development, organizational culture and organizational change.
2. Apply systems thinking to organizational problems.
3. Use action research and organizational diagnosis to guide interventions.
4. Compare major change models and identify their appropriate uses.
5. Design interventions involving teams, culture, engagement and transformation.
6. Analyze the sources and ethical management of resistance to change.
7. Evaluate change outcomes using appropriate qualitative and quantitative evidence.
8. Explain the strategic role of HR professionals in organizational change.

Organizational Development: Meaning, Scope and Values

OD is a planned process of organization-wide improvement based on behavioral-science knowledge. Its traditional values include participation, human dignity, openness, inquiry, collaboration and the development of both organizational performance and employee well-being.

OD differs from several related activities:

These boundaries overlap. A digital transformation, for example, may require change-management communication, leadership development, revised performance systems and an OD intervention to rebuild cross-functional collaboration.

OD should not be treated as a neutral technical process. Decisions about what counts as “improvement” reflect values and power relationships. A program that increases productivity by exhausting employees may achieve a narrow performance target while damaging organizational health. Responsible OD therefore considers effectiveness, fairness, voice, inclusion, sustainability and stakeholder consequences.

Systems Thinking and the Organization as an Open System

Systems thinking examines patterns, relationships and interdependence rather than isolated events. An organizational system includes:

• Inputs: people, capital, information, materials, technology and legitimacy.
• Transforming processes: leadership, decision-making, coordination, production, service delivery and learning.
• Outputs: financial results, customer value, innovation, employee outcomes and social impact.
• Feedback: information about results that enables adjustment and learning.
• Environment: competitors, regulators, labor markets, communities, suppliers and technological forces.

A systems perspective warns HR practitioners against linear explanations. High turnover may be attributed to weak employee commitment, but further investigation may reveal unrealistic workloads, poor supervision, inconsistent scheduling, limited career opportunities or inequitable rewards. The visible symptom is not necessarily the system’s root cause.

Three systems principles are especially useful. First, interdependence means that a change in one component can create consequences elsewhere. Second, emergence means that organizational patterns, such as trust or cynicism, arise from repeated interactions and cannot be explained solely by individual traits. Third, feedback means that actions may produce reinforcing or balancing effects. For example, increased performance pressure may initially raise output, but fatigue can later increase errors and absence, reducing output.

The congruence perspective associated with Nadler and Tushman proposes that organizational performance depends on the fit among work, people, formal arrangements and informal organization. A technically sound restructuring may fail if employee capabilities, informal networks and cultural expectations do not fit the new design.

The Burke–Litwin model extends this logic by distinguishing transformational factors—external environment, mission and strategy, leadership and organizational culture—from transactional factors such as structure, management practices, work climate, task requirements, motivation and individual needs. The model is valuable because it encourages diagnosis at multiple levels rather than assuming that a single training intervention can solve a strategic problem.

Organizational Culture

Organizational culture is the pattern of shared assumptions, values and norms that guides how members perceive, think and act. Edgar Schein distinguishes three levels:

1. Artifacts: visible structures, language, rituals, office arrangements, technology and behavior.
2. Espoused values: stated principles, strategies and philosophies.
3. Basic underlying assumptions: deeply held and often unconscious beliefs about authority, risk, time, relationships and human behavior.

Artifacts are easy to observe but difficult to interpret. A company may display posters about collaboration while rewarding individual competition. The discrepancy between espoused values and enacted practices is often more influential than formal statements.

Culture is not automatically good or bad. Its usefulness depends on context. A culture that values caution may protect a safety-critical organization but hinder rapid experimentation in a volatile market. Subcultures may exist among departments, professions, locations or demographic groups. HR professionals should therefore avoid describing “the culture” as if it were uniform.

Culture can be assessed through interviews, observation, document analysis, focus groups, employee surveys, critical-incident analysis and review of people data. A survey may reveal low trust, but interviews may explain whether the issue concerns inconsistent leadership, lack of procedural justice or fear of retaliation. Triangulation—using several sources of evidence—improves diagnosis.

Culture change is difficult because basic assumptions are reinforced by selection, socialization, promotion, reward and sanction. It is not achieved merely by publishing new values. Leaders must model the values, systems must reinforce them, and employees must experience credible evidence that the organization has changed.

Organizational Diagnosis

Organizational diagnosis is the systematic process of collecting and interpreting evidence about how an organization functions and where improvement is needed. Diagnosis should precede intervention, although diagnosis and action often develop iteratively.

A useful diagnostic sequence is:

1. Clarify the presenting issue. Define who experiences the problem, when it occurs and why it matters.
2. Identify stakeholders. Include employees, managers, customers, unions, senior leaders and other affected groups.
3. Develop a preliminary systems map. Consider strategy, structure, processes, technology, people, leadership and culture.
4. Collect evidence. Use surveys, interviews, focus groups, observation, records and performance indicators.
5. Analyze patterns. Compare groups, locations and time periods while avoiding unsupported causal claims.
6. Test interpretations. Share findings with stakeholders and invite correction or additional evidence.
7. Prioritize issues. Consider impact, urgency, feasibility, equity and strategic relevance.
8. Agree on action and evaluation criteria. Define what improvement will look like and how it will be assessed.

Diagnosis must distinguish correlation from causation. If engagement scores and customer satisfaction rise together, this does not prove that engagement caused the improvement. Other factors may include seasonality, staffing levels, market conditions or leadership changes.

Useful diagnostic questions include:

• What outcomes are below expectation?
• Which groups experience the problem most strongly?
• What behaviors and processes produce the current outcome?
• What formal policies and informal norms reinforce those behaviors?
• What forces support change, and what forces preserve the status quo?
• Who benefits from the current arrangement, and who bears its costs?
• What evidence would disconfirm our initial explanation?

Action Research as an OD Method

Action research, strongly associated with Kurt Lewin, combines inquiry and practical intervention. It treats organizational members as participants in knowledge creation rather than passive subjects. A common cycle is:

Entry and contracting → diagnosis → feedback → joint planning → action → evaluation → further diagnosis

Entry involves establishing purpose, scope, roles, confidentiality and access to information. Contracting is particularly important when an HR professional or external consultant has unequal power relative to employees. Participants should understand how data will be used and what the process can realistically deliver.

Feedback should be timely, understandable and presented in a way that protects individuals. Joint planning converts findings into interventions. Action may involve redesigning work, developing leaders, changing team routines, revising rewards or improving communication. Evaluation tests whether the intervention produced intended and unintended effects.

Action research has several advantages: it builds ownership, integrates learning with implementation and allows adaptation. Its limitations include time demands, possible political manipulation, researcher bias and the risk that participation becomes symbolic rather than influential.

Major Models of Planned Change

Lewin’s Three-Phase Model

Lewin’s model describes change as unfreezing, changing and refreezing. Unfreezing creates readiness by questioning existing assumptions and demonstrating the need for change. Changing involves experimenting with new behaviors, structures or processes. Refreezing stabilizes useful new patterns through systems, norms and reinforcement.

The model is a helpful teaching framework, but “refreezing” should not imply permanent stability in turbulent environments. In contemporary organizations, the final phase may be better understood as institutionalizing learning while preserving adaptability.

Kotter’s Eight-Step Model

Kotter proposes: create urgency; build a guiding coalition; form a strategic vision and initiatives; enlist a volunteer army; remove barriers; generate short-term wins; sustain acceleration; and institute change. The model emphasizes leadership, communication, momentum and reinforcement. It is most useful when a significant, coordinated change requires broad organizational mobilization. Its sequential presentation should not be interpreted rigidly; organizations often revisit earlier activities.

ADKAR

The ADKAR framework focuses on individual adoption: Awareness of the need for change, Desire to support it, Knowledge of how to change, Ability to perform new behaviors, and Reinforcement to sustain them. It is useful for identifying adoption barriers at the employee level. It does not, by itself, replace system-level diagnosis. Employees may possess knowledge and ability yet still face impossible workloads or contradictory reward systems.

Appreciative Inquiry

Appreciative Inquiry emphasizes discovering what works, imagining what could be, designing desired conditions and embedding them in practice. Its positive orientation can generate energy and reveal existing strengths. However, it should not suppress discussion of harm, inequality or failure. A credible inquiry includes both strengths and difficult realities.

Designing OD Interventions

An intervention is a deliberate set of activities intended to improve organizational functioning. Intervention selection should follow diagnosis, not consultant preference. Common categories include:

Individual and interpersonal interventions

These include coaching, mentoring, career development, conflict-management training and feedback processes. They are appropriate when capability, role clarity or interpersonal skill is a significant factor. They are inappropriate when the primary problem is structural—for example, asking employees to “communicate better” when reporting lines create conflicting instructions.

Team interventions

Team development may involve establishing a shared purpose, clarifying roles, developing norms, reviewing decision rights, improving psychological safety and conducting structured retrospectives. Effective team interventions connect interpersonal relationships with task performance. A team-building event alone rarely resolves unclear authority, inadequate resources or incompatible incentives.

A practical team diagnostic can examine five questions:

1. Is the team’s purpose understood and linked to organizational strategy?
2. Are responsibilities and decision rights clear?
3. Are members dependent on one another in ways that require coordination?
4. Can members raise concerns and challenge assumptions safely?
5. Does the team review results and learn from experience?

Structural and process interventions

These may include redesigning jobs, simplifying workflows, clarifying governance, forming cross-functional teams, decentralizing decisions or improving technology. Process redesign should consider employee workload, accessibility, data protection and the effects on service quality.

Human resource system interventions

Recruitment, onboarding, performance management, rewards, promotion, succession and learning systems communicate what the organization values. If collaboration is strategic but bonuses are based entirely on individual output, the HR system creates cultural contradiction.

Strategic and transformational interventions

Transformation may involve a new business model, merger, digital operating model, sustainability strategy or organizational identity. Such changes require a compelling case, leadership alignment, stakeholder participation, capability building and ongoing evaluation. Transformation should not be reduced to technology acquisition or a rebranding exercise.

Employee Engagement and Psychological Safety

Engagement refers to the quality of an employee’s connection with work and the organization. It includes energy, involvement, commitment and willingness to contribute. Engagement is influenced by meaningful work, supportive leadership, autonomy, fairness, growth opportunities, manageable demands and confidence that employee voice matters.

Engagement surveys are useful only when followed by credible action. Repeatedly asking for feedback without responding can increase cynicism. A responsible process explains the purpose of the survey, protects confidentiality, reports results honestly and identifies actions with owners and timelines.

Psychological safety, associated with Amy Edmondson’s research, is a shared belief that the team is safe for interpersonal risk-taking. It does not mean low standards or agreement without challenge. A psychologically safe team can admit mistakes, ask questions and disagree while maintaining accountability. Leaders promote it by inviting dissent, responding constructively to bad news and separating learning conversations from blame.

Managing Resistance to Change

Resistance is often described as an individual defect, but it may be a rational response to uncertainty, loss, exclusion, poor history or perceived injustice. Sources include:

• fear of job loss, status loss or reduced autonomy;
• inadequate information or conflicting messages;
• lack of capability or resources;
• change fatigue and competing initiatives;
• low trust in leaders;
• perceived unfairness in process or outcomes;
• professional or cultural identity threats; and
• genuine concerns about safety, quality or ethics.

Resistance can be overt, such as open disagreement, or covert, such as delay, minimal compliance and withdrawal. HR professionals should distinguish resistance to the change itself from resistance to how the change is being implemented.

Appropriate responses include meaningful participation, transparent communication, consultation, training, transition support, negotiation and redesign. Coercion may produce short-term compliance but can damage trust and create hidden resistance. Leaders should not promise that every preference will be adopted; participation requires honest boundaries and explanation of decisions.

A useful approach is to ask: What is the person protecting? What evidence supports the concern? Is the concern about capability, capacity, identity, fairness or trust? What can be changed in the proposal or implementation process? This converts resistance from an obstacle into diagnostic information.

Ethical, Legal and Governance Considerations

Change initiatives must respect dignity, privacy, equality and due process. Important safeguards include:

• collecting only data necessary for the stated purpose;
• explaining consent, confidentiality and data access;
• protecting employees from retaliation for honest feedback;
• assessing disparate effects on protected or vulnerable groups;
• consulting employee representatives where required;
• documenting selection and redundancy decisions fairly;
• ensuring accessibility for employees with disabilities;
• validating automated tools and monitoring algorithmic bias; and
• communicating material risks honestly.

Employee-surveillance technologies and AI-based sentiment tools require particular caution. Text analytics may misinterpret cultural differences, sarcasm or minority communication patterns. Predictive models can reproduce historical discrimination if trained on biased data. Human review, explainability, data minimization, security and appeal mechanisms are essential. AI should support—not replace—professional judgment and meaningful employee voice.

Evaluating Change and OD Effectiveness

Evaluation should be designed before implementation. A balanced evaluation may include:

• Reaction: How did participants experience the intervention?
• Learning: What knowledge, skills or shared understanding changed?
• Behavior: Are new practices visible in work?
• Results: Did performance, quality, retention, safety or customer outcomes improve?
• Equity and well-being: Were benefits and burdens distributed fairly?
• Sustainability: Can the new practice continue with available resources?

A simple improvement rate can be calculated as:

Here, the baseline value is the pre-intervention measure and the post-intervention value is the measure after implementation. The formula is meaningful when the measure has a meaningful zero and the comparison periods and definitions are consistent. For example, if voluntary turnover falls from 20 employees per 100 employees to 15 employees per 100 employees, the relative change is (15 − 20) ÷ 20 × 100% = −25%. This indicates a 25% reduction relative to baseline; it does not prove that the intervention caused the reduction.

More rigorous evaluation may use comparison groups, interrupted time-series analysis, interviews and process measures. HR professionals should report unintended consequences, such as improved output accompanied by increased burnout. Evaluation is not merely a justification exercise; it is part of organizational learning.

Illustrative Case: The Northstar Service Transformation

Background

Northstar, a fictional regional insurance provider, introduced a digital claims platform to reduce processing time and improve customer access. Senior leaders expected the platform to be fully adopted within six months.

Problem

After four months, adoption was uneven. Claims officers reported that the system was difficult to navigate, supervisors continued to demand paper reports, and customer complaints increased. Senior management initially concluded that employees were resistant to technology.

Analysis

The HR development team used an action-research approach. Interviews and observation showed four interacting problems. First, employees had received technical demonstrations but little practice with realistic cases. Second, the old and new systems operated simultaneously, creating duplicated work. Third, performance targets rewarded speed under the old process. Fourth, employees feared that automation would eliminate jobs, but leaders had not addressed the concern directly.

A survey showed lower confidence among experienced employees, while focus groups revealed that these employees possessed valuable knowledge about exceptional claims. The issue was therefore not simply individual resistance. It involved work design, leadership communication, performance management, capability and trust.

Approach and Solution

A cross-functional guiding team redesigned the implementation. It piloted the platform in one branch, appointed experienced claims officers as paid peer coaches, removed duplicate reporting, revised performance measures to include quality and adoption, and created weekly feedback sessions. Leaders explained the likely job changes and committed to retraining before considering redeployment. System defects were logged and prioritized with employee input.

Outcome

After three months, use of the digital workflow increased substantially, processing delays decreased and employees reported greater confidence. Not every concern disappeared: workload remained high during peak periods, and the organization had to continue monitoring fairness in performance ratings. The pilot was therefore treated as a learning stage rather than proof that all branches would experience identical results.

Learning Points

1. A technology problem may actually be a systems problem.
2. Training is insufficient when processes, incentives and leadership messages conflict.
3. Experienced employees can be sources of implementation knowledge rather than barriers.
4. Participation is most credible when it influences decisions.
5. Pilots, feedback and evaluation reduce the risk of imposing a flawed design at scale.

Strategic Role of the HR Professional

HR professionals contribute to OD in five connected ways. They act as diagnosticians who interpret evidence without prematurely choosing a solution. They act as designers who align people practices with strategy. They act as facilitators who create conditions for participation and learning. They act as ethical stewards who protect fairness, privacy and employee voice. Finally, they act as evaluators who test whether change improves both organizational and human outcomes.

This role requires business literacy, data interpretation, facilitation, communication, conflict management and ethical judgment. It also requires humility. HR should not assume that its formal authority gives it complete understanding of employee experience. Credible OD is co-created with those who perform and are affected by the work.

Challenges and Limitations

OD initiatives may fail because of superficial diagnosis, unrealistic timelines, leadership inconsistency, weak sponsorship, intervention overload or inadequate resources. Culture programs may become symbolic if reward and promotion decisions remain unchanged. Participation may be manipulated to create the appearance of legitimacy. Engagement metrics may encourage managers to improve scores rather than improve work. Change models may be applied mechanically despite differences in context.

There are also measurement limitations. Organizational outcomes are influenced by multiple causes, and some important changes—trust, identity, inclusion and learning—are difficult to measure precisely. Quantitative indicators should therefore be combined with qualitative evidence and interpreted cautiously.

Best-Practice Principles

1. Diagnose before prescribing.
2. Treat the organization as an interconnected system.
3. Involve affected employees early and meaningfully.
4. Align leadership behavior, structure, processes and rewards.
5. Communicate what is known, unknown and still being decided.
6. Address both capability and capacity.
7. Use pilots and feedback when uncertainty is high.
8. Evaluate intended and unintended outcomes.
9. Protect privacy, dignity, inclusion and psychological safety.
10. Institutionalize learning without assuming that change is ever permanently complete.

Chapter Summary

Organizational development is a planned, participative and evidence-informed approach to improving organizational effectiveness, health and learning. Systems thinking shows that outcomes arise from relationships among strategy, structure, people, technology, processes, leadership and culture. Organizational culture consists of artifacts, espoused values and underlying assumptions; sustainable culture change requires alignment between stated values and lived systems.

Organizational diagnosis uses multiple sources of evidence to identify patterns and prioritize issues. Action research links diagnosis, participation, intervention and evaluation in an iterative cycle. Lewin, Kotter, ADKAR and Appreciative Inquiry provide useful but context-dependent change frameworks. Interventions may target individuals, teams, structures, processes, HR systems or transformation.

Engagement and psychological safety depend on meaningful work, fairness, support, voice and learning. Resistance should be interpreted as information about risk, capacity, identity, trust or justice rather than automatically treated as misconduct. Ethical OD protects privacy, dignity, equality and due process, especially when using employee analytics or AI. Effective HR professionals integrate strategic judgment with evidence, facilitation, ethical stewardship and continuous evaluation.

Key Terms

Organizational development: A planned, participative effort to improve organizational effectiveness, health and learning.

Organizational change: A movement from current patterns of work or behavior toward desired future conditions.

Organizational transformation: A fundamental change in strategy, identity, operating model or capabilities.

Systems thinking: Analysis of relationships, interdependence, feedback and patterns within a whole system.

Open system: A system that exchanges resources, information and influence with its environment.

Organizational culture: Shared assumptions, values and norms that guide organizational behavior.

Artifacts: Visible manifestations of culture, such as language, rituals and structures.

Espoused values: Principles and beliefs an organization claims to support.

Basic assumptions: Deep, often unconscious beliefs that shape interpretation and behavior.

Organizational diagnosis: Systematic collection and interpretation of evidence about organizational functioning.

Action research: An iterative process linking inquiry, participation, action and evaluation.

Intervention: A deliberate activity designed to improve organizational functioning.

Psychological safety: A shared belief that interpersonal risk-taking is safe within a team.

Employee engagement: The quality of an employee’s energy, involvement and connection with work.

Resistance to change: Actions or reactions that oppose, delay or question a change initiative.

Change readiness: The extent to which people and systems are prepared and willing to support change.

Congruence: The degree of fit among organizational components such as work, people and structure.

Stakeholder: A person or group affected by, able to influence or concerned about an organizational decision.

Institutionalization: Embedding a new practice into routines, systems and norms so that it is sustained.

Triangulation: Using multiple evidence sources or methods to improve confidence in a diagnosis.

Review Questions

Short Answer Questions

1. Define organizational development and distinguish it from training.
2. What are the three levels of culture in Schein’s framework?
3. Explain why systems thinking is useful in diagnosing turnover.
4. What are the stages of the action-research cycle?
5. Define psychological safety and explain how it differs from low performance standards.

Long Answer Questions

1. Compare Lewin’s Three-Phase Model, Kotter’s Eight-Step Model and ADKAR. Explain the situations in which each may be most useful.
2. Discuss how organizational culture is created and reinforced through leadership, selection, socialization and reward systems.
3. Explain the role of organizational diagnosis in preventing inappropriate OD interventions.
4. Analyze the ethical issues involved in using AI-based employee sentiment or performance tools during organizational change.
5. Discuss how HR can align engagement initiatives with organizational strategy rather than treating engagement as a survey score.

Analytical / Application Questions

1. A hospital reports rising nurse turnover, frequent errors and low engagement. Using systems thinking, identify at least four possible interacting causes and propose a diagnostic plan.
2. A company introduces a collaboration value but continues to reward only individual sales results. Diagnose the cultural contradiction and design an intervention.
3. An organization is implementing an AI-supported recruitment system, and employees fear job losses and algorithmic bias. Apply a change model and ethical safeguards to develop an implementation approach.

Multiple Choice Questions with Answers

Question 1

Which statement best describes organizational development?

A. A one-time technical training program for new employees

B. A planned and participative effort to improve organizational effectiveness and learning

C. A payroll process used to calculate employee compensation

D. A disciplinary procedure for employees who resist change

Correct Answer: B. A planned and participative effort to improve organizational effectiveness and learning

Question 2

Which of the following is an example of an organizational artifact?

A. An unconscious belief that managers should never be challenged

B. A stated commitment to innovation

C. A visible ritual used to recognize employee achievements

D. An assumption that customers are always correct

Correct Answer: C. A visible ritual used to recognize employee achievements

Question 3

What is the central contribution of systems thinking to organizational diagnosis?

A. It isolates individual employee weaknesses from organizational factors

B. It examines relationships and interdependence among organizational components

C. It replaces evidence collection with managerial intuition

D. It assumes that every organizational problem has one direct cause

Correct Answer: B. It examines relationships and interdependence among organizational components

Question 4

Which sequence correctly represents the action-research cycle described in the chapter?

A. Recruitment, selection, promotion, retirement

B. Entry, diagnosis, feedback, action, evaluation and further diagnosis

C. Planning, budgeting, purchasing, auditing

D. Awareness, dismissal, replacement, closure

Correct Answer: B. Entry, diagnosis, feedback, action, evaluation and further diagnosis

Question 5

In the ADKAR framework, which element concerns the capability to perform new behaviors?

A. Awareness

B. Desire

C. Ability

D. Reinforcement

Correct Answer: C. Ability

Question 6

A company provides software training but leaves duplicate reporting requirements and conflicting performance targets unchanged. What does this most clearly illustrate?

A. The need to address system alignment rather than training alone

B. The success of a purely individual intervention

C. The irrelevance of organizational diagnosis

D. The absence of any possible resistance to change

Correct Answer: A. The need to address system alignment rather than training alone

Question 7

Which response is most consistent with ethical management of resistance?

A. Suppressing criticism to maintain change momentum

B. Treating all disagreement as misconduct

C. Investigating whether resistance reflects concerns about capacity, fairness or trust

D. Guaranteeing that every employee preference will be adopted

Correct Answer: C. Investigating whether resistance reflects concerns about capacity, fairness or trust

Question 8

If voluntary turnover decreases from 20 employees per 100 employees to 15 employees per 100 employees, what is the relative change from baseline?

A. 5% reduction

B. 15% reduction

C. 20% reduction

D. 25% reduction

Correct Answer: D. 25% reduction

Question 9

What is psychological safety?

A. The absence of performance expectations within a team

B. A shared belief that interpersonal risk-taking is safe

C. A guarantee that employees will never experience disagreement

D. A formal policy prohibiting feedback

Correct Answer: B. A shared belief that interpersonal risk-taking is safe

Question 10

Which practice is most appropriate when using AI-based employee analytics during change?

A. Collecting all available data without informing employees

B. Using automated results as final decisions without human review

C. Applying data minimization, bias monitoring, transparency and appeal mechanisms

D. Ignoring disparate effects if overall productivity improves

Correct Answer: C. Applying data minimization, bias monitoring, transparency and appeal mechanisms