Under Article 10 of the Human Rights Act 1998, “everyone has the right to freedom of expression” in the UK. The law goes on to say that this freedom “may be subject to formalities, conditions, restrictions or penalties as are prescribed by law and are necessary in a democratic society."
These may be “in the interests of national security, territorial integrity or public safety, for the prevention of disorder or crime, for the protection of health or morals, for the protection of the reputation or rights of others, for preventing the disclosure of information received in confidence, for maintaining the authority and impartiality of the judiciary.”
There is now and never had been the right 'free speech in the UK, or anywhere for that matter.
In the US, this is what the Constitution says:
Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.[6]
Note the word 'Congress'.... But speech is shackled, even in the US. Hence why the President excluded AP reporters from a press conference. He didn't like the questions.