In the UK you do have a right to see your notes. Written records are held under the terms of The Data Protection Act, which means everyone has a legal right to see what's been written about them, unless there's evidence that seeing them would cause exceptional harm (and even in those circumstances I think it ultimately comes down to a judge to decide whether that's the case or not).
What's written varies, though, depending on whether you are dealing with private or public sector. Two private therapists I've seen went to great lengths to explain note keeping to me, and said that they don't write what they think about you, it's just notes about what you discuss to jog their memory for the next session and to help them plan for future sessions (exercises or techniques to suggest or work on, for example).
Public sector, though, and I've had all manner of things written about me - I'm a drama queen, manipulative, I lie and exaggerate to get attention, you name it, it's all there. The public sector is well known in the UK for demonising patients to disguise the massive short comings in help and support - instead of focusing on making you well they can just say you're making it all up and wash their hands of you. Arseholes.