In reply to Paul Lawley-Jones.

@KTS915 Are you saying that because there are so many more things in British law that are explicitly not included as protected speech, "censorship" is more likely to be seen in the UK as something a public authority does, not private individuals? That makes sense. In the US it's mostly private entities that act as censors by exercising "editorial control" or managing "business interests." There is indeed a legal distinction between "editorial control" and "censorship," but what it really amounts to is legal versus illegal censorship. In the general sense, any limiting of someone's speech anywhere or for any reasons is a type of censorship based in someone else's values that determine what the limits ought to be on expression.

Regarding the public/private distinction being a US concept, I think that is entirely incorrect. Both the UK and US make important public/private distinctions when determining the limits of free speech and censorship.The HRA created a key public/private distinction for the UK in 1998 when it codified free speech as a right free from "interference by public authority." In recent cases in both the US and UK where employers demoted or fired employes for comments they made on Facebook, decisions have been made for or against the employers largely on the basis of whether the comments were public or private speech.