Psychotherapy notes are the only notes that a patient does not have a right to see - for their own protection. Therapist's may write down something that could be harmful or taken harmfully to the client.

If a client is showing signs of something the therapist may make a note of something - i.e. patient talking about father, wondering if there may be any s*xual abuse. That's something just for THEIR record, but may cause you harm to see.