The author does not know what he is talking about.
Scotland is in the UK.
It has a law on the books in which a hate crime may be being truthful about gender being determined by biology.
Harry Potter author J K Rowling challenged it and for now it seems the police are not going to charge anyone although over 7000 criminal complaints were made.
For all practical purposes the UK has no freedom of speech because it does not have a written constitution guaranteeing 1A.
In American we have constitution guaranteeing 1A and we also have 2A which backs up 1A.
There was no “1A” until the US Constitution. Before that, it was “freedom of speech”, but I believe also that no lawmaking body would have conceived of putting the guarantee thereof in the so-called “negative liberty” format where governments could never have the power of taking it away from the people.
Since the First Amendment covers far more than freedom of speech, I did mean to include the other rights listed. Sorry.
The 2A makes all the others possible.