It is interesting to understand what this call is for and what the mediaanalysisd daemon is actually doing/sending, but just triggering LittleSnitch while browsing local documents I'm not sure is enough to draw a direct connection. Correlation perhaps, but honestly I think before making the claim that Apple is sending specific document information to their servers, it'd be better to get something a bit more concrete.
Checking with just activity monitor on the mediaanalysisd process and its network traffic while browsing through pictures, the sent/received data is bytes in size; I'm not in a position to do a proper network capture, but already I question what those few bytes are and if it's really related to my media browsing activities or just background noise. There is a fairly significant amount of received traffic (like close to 200 GiB) compared to the sent traffic (13 GiB), so I'm not quite convinced that this correlates to media scanning.
Passing psgrep with mediaanalysisd to lsof shows a lot of fairly normal background processes/daemons like webkit, AppleSupport, the AppStore, etc., so I find myself thinking it's more a general process despite the name, but far more research of actual packet data is needed.
The only mistake I think you've made is that I think your conclusion is premature to connect file browsing to this daemon, as it seems to handle a lot of stuff besides the implication that it scans documents or that it's specifically related to CSAM.
Basically, more information is needed in my opinion.
Edit: Changed "feel" to "think" in 2nd to last text block to correct my own language issue.